H.R. Bill 7108, the “Suspending Normal Trade Relations with Russia and Belarus Act,” (hereafter, “Act”) has been passed by the House and Senate and signed into law by the President today. This means that tomorrow (April 9), the duty rates set forth in Column 2 of the Harmonized Tariff Schedule of the United States (“HTSUS”) will apply to all entered products of Russian and Belarussian origin. 

Specifically, the Act states:

Notwithstanding any other provision of law, beginning the day after the date of the enactment of this Act, the rates set forth in column 2 of the [HTSUS] shall apply to all products of the Russian Federation and the Republic of Belarus.

To avoid the Column 2 duties, clients should instruct their broker immediately to file Customs entry certified from summary with today’s elected entry date for such merchandise. The disposition of Russian-origin and Belarus-origin merchandise held in inventory in foreign-trade zones (FTZs) prior to enactment of the Act is not explicitly addressed. However, based on the plain language of the Act, it does not appear that merchandise in Privileged Foreign (PF) zone status would benefit from Column 1 rates if entered on or after the Act is effective. Clients with Russian imports should review the HTSUS to determine the specific impact of the change from Column 1 to Column 2 duty rates.

Contact Marshall Miller, Sean Murray, Bryan Brown or Linda King to discuss options or with questions.